REGULATING ARTIFICIAL INTELLIGENCE IN CORPORATE GOVERNANCE: A COMPARATIVE OVERVIEW OF THE UNITED STATES, THE EUROPEAN UNION, AND UZBEKISTAN

Authors

  • Nuriddin Khudoyberdiev LL.M., Penn State Law, The Pennsylvania State University, USA; LL.M. and LL.B., Tashkent State University of Law, Uzbekistan

DOI:

https://doi.org/10.55640/

Keywords:

artificial intelligence; corporate governance; comparative law; EU AI Act; NIST AI Risk Management Framework; Uzbekistan AI Strategy 2030; algorithmic accountability; board oversight; risk-based regulation.

Abstract

Artificial intelligence is reshaping corporate decision-making, internal control, and disclosure practices across every major economy. Yet the legal frameworks that govern how companies deploy AI in their governance structures diverge sharply between jurisdictions. This article offers a concise comparative overview of three contrasting approaches. The United States has produced a layered and decentralized regime built on voluntary federal standards, sectoral securities regulation, and competing state statutes, recently overlaid by an executive-branch push for federal preemption. The European Union has adopted a horizontal and risk-based regulation in the AI Act of 2024, supplemented by the General Data Protection Regulation and the November 2025 Digital Omnibus simplification package. Uzbekistan has moved rapidly from strategic planning under Presidential Resolution PP-358 of October 2024 to a comprehensive AI law approved by the Senate in November 2025, but a number of corporate-governance gaps remain. After mapping each regime, the article distills six general recommendations for Uzbek reform, focused on risk classification, board-level oversight, disclosure, developer-deployer liability, institutional capacity, and international alignment.

Downloads

Download data is not yet available.

References

1. Presidential Resolution of the Republic of Uzbekistan No. PP-358 of October 14, 2024, On the Approval of the Strategy for the Development of Artificial Intelligence Technologies until 2030, https://lex.uz/docs/7159258.

2. Cabinet of Ministers of the Republic of Uzbekistan, Resolution No. 425 of 2025, Priority AI Projects for 2025–2026.

3. Law of the Republic of Uzbekistan, On the Regulation of Relations Arising from the Use of Artificial Intelligence (approved by the Senate of the Oliy Majlis at its 11th plenary session, November 1, 2025).

4. Regulation (EU) 2024/1689 of the European Parliament and of the Council of June 13, 2024, laying down harmonised rules on artificial intelligence (Artificial Intelligence Act), O.J. L, 2024/1689.

5. Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (General Data Protection Regulation), Article 22.

6. European Commission, Proposal for a Regulation on the simplification of the implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI), COM(2025) final, November 19, 2025.

7. Council of the EU and European Parliament, Provisional Agreement on the Digital Omnibus on AI (May 7, 2026), Press Release available at https://www.consilium.europa.eu.

8. European Commission, AI Act — Implementation Timeline, Shaping Europe’s Digital Future, https://digital-strategy.ec.europa.eu.

9. White House, Office of Science and Technology Policy, Blueprint for an AI Bill of Rights (October 2022), https://bidenwhitehouse.archives.gov/ostp/ai-bill-of-rights/.

10. National Institute of Standards and Technology, Artificial Intelligence Risk Management Framework (AI RMF 1.0), NIST AI 100-1 (January 26, 2023).

11. Executive Order 14365, Ensuring a National Policy Framework for Artificial Intelligence (December 11, 2025).

12. White House, National Policy Framework for Artificial Intelligence (March 20, 2026).

13. Colorado Senate Bill 24-205, Consumer Protections for Artificial Intelligence (signed May 17, 2024).

14. Colorado Senate Bill 26-189, An Act Concerning Accountability for Automated Decision-Making Technology (2026), effective January 1, 2027.

15. xAI Corp. v. Weiser, No. 1:26-cv-XXXXX (D. Colo. filed April 9, 2026); U.S. Department of Justice Complaint in Intervention (April 24, 2026); Order Staying Enforcement (April 27, 2026).

16. U.S. Securities and Exchange Commission, Investor Advisory Committee, Recommendation Regarding Disclosure of Artificial Intelligence’s Impact on Operations (December 4, 2025).

17. In re Caremark Int’l Inc. Derivative Litigation, 698 A.2d 959 (Del. Ch. 1996); Marchand v. Barnhill, 212 A.3d 805 (Del. 2019).

18. OECD.AI Policy Observatory, The Strategy for the Development of Artificial Intelligence Technologies until 2030 — Uzbekistan (last updated 2025).

19. Ernst and Young, Study on the Relevance and Impact of Artificial Intelligence for Company Law and Corporate Governance — Final Report (2021), prepared for the European Commission.

20. BBC News, Amazon scrapped “sexist AI” tool (October 10, 2018), https://www.bbc.com/news/technology-45809919.

Downloads

Published

2026-04-25

Issue

Vol. 5 No. 4 (2026): Journal of Multidisciplinary Sciences and Innovations

Section

Articles

License

Creative Commons License

This work is licensed under a Creative Commons Attribution 4.0 International License.

Authors retain the copyright of their manuscripts, and all Open Access articles are disseminated under the terms of the Creative Commons Attribution License 4.0 (CC-BY), which licenses unrestricted use, distribution, and reproduction in any medium, provided that the original work is appropriately cited. The use of general descriptive names, trade names, trademarks, and so forth in this publication, even if not specifically identified, does not imply that these names are not protected by the relevant laws and regulations.

How to Cite

REGULATING ARTIFICIAL INTELLIGENCE IN CORPORATE GOVERNANCE: A COMPARATIVE OVERVIEW OF THE UNITED STATES, THE EUROPEAN UNION, AND UZBEKISTAN. (2026). Journal of Multidisciplinary Sciences and Innovations, 5(4), 1041-1049. https://doi.org/10.55640/

Similar Articles

31-40 of 3890

You may also start an advanced similarity search for this article.